The country of origin of a constant velocity axle

N354393 October 22, 2025 OT:RR:NC:N2:206 CATEGORY: Origin Victor Shengli VSolution Manufacturing (Thailand) Co., Ltd. 368/8 Moo.8, Map Kha, Nikhom Phatthana Rayong 21180 Thailand RE: The country of origin of a constant velocity axle Dear Mr. Shengli: In your letter dated September 30, 2025, you requested a country of origin ruling on a constant velocity axle (CV axle) for marking purposes. The article under consideration is a CV axle, Part Number MFG#: TO-68398BA, also known as a half shaft, which is used in passenger vehicles. The primary function of the CV axle is to transmit torque generated by the engine to the vehicle’s wheels, propelling the vehicle forward. Since the vehicle’s suspension system and wheels need to move up and down and turn, the design of the CV axle allows them to accommodate these various movements without affecting the smooth transfer of power. The CV axle consists of an outer CV joint, intermediate shaft, inner CV joint, and accessories, such as dust boots, grease, a snap ring, nut, clamp, and C-ring. According to the production documents submitted with your request, the outer CV joint is composed of Thai sourced housing and steel balls, and Chinese sourced inner race and cage forgings. The forgings are further machined, grinded, heat treated, shot blasted, and splined, if applicable, in Thailand into finished subcomponents of the outer CV joint. The intermediate shaft is wholly produced in Thailand. The inner CV joint is composed of Chinese sourced housing and tripod forgings, which are machined, splined, grinded, heat treated, and coated in Thailand into identifiable subcomponents of the inner CV joint. The accessories, such as the dust boots and grease are sourced from Thailand, while the finished snap ring, nut, clamp, and C-ring are imported from China. The final assembly of the CV axle involves pressing the tripod with the intermediate shaft, installing the snap ring, dust boots, clamp, and C-ring, greasing the outer CV joint, pressing, greasing the inner CV joint, installing it with the rest of the assembly, clamping, installing the nut, and testing and coating with the arti-rust oil. Section 304 of the Tariff Act of 1930, as amended (19 U.S.C. 1304), provides that unless excepted, every article of foreign origin imported into the United States shall be marked in a conspicuous place as legibly, indelibly, and permanently as the nature of the article (or its container) will permit, in such a manner as to indicate to the ultimate purchaser in the United States, the English name of the country of origin of the article. Congressional intent in enacting 19 U.S.C. 1304 was “that the ultimate purchaser should be able to know by an inspection of the marking on the imported goods the country of which the goods is the product. The evident purpose is to mark the goods so that at the time of purchase the ultimate purchaser may, by knowing where the goods were produced, be able to buy or refuse to buy them, if such marking should influence his will.” See United States v. Friedlander & Co., 27 C.C.P.A. 297, 302 (1940). Part 134 of the U.S. Customs and Border Protection (“CBP”) Regulations (19 CFR 134) implements the country of origin marking requirements and exceptions of 19 U.S.C. 1304. Section 134.1(b), CBP Regulations (19 CFR 134.1(b)), defines “country of origin” as the country of manufacture, production, or growth of any article of foreign origin entering the United States. Further work or material added to an article in another country must effect a substantial transformation in order to render such other country the “country of origin” within the meaning of the marking laws and regulations. A substantial transformation occurs when, as a result of manufacturing process, a new and different article emerges, having a distinct name, character or use, which is different from that originally possessed by the article or material before being subjected to the manufacturing process. See United States v. Gibson-Thomsen Co., Inc., 27 C.C.P.A. 267 (C.A.D. 98) (1940). In ruling N336861, dated December 18, 2023, CBP stated that the character of a CV axle was the intermediate shaft and CV joints. In the present case, the CV joints are produced in China and Thailand, while the intermediate shaft is of Thai origin. Although individual processes in Thailand of each subcomponent from China do not result in a substantial transformation, the overall materials and labor costs attributed to Thailand are significantly higher than China. Furthermore the final assembly of all components also occurs in Thailand. As a result, it is the opinion of this office that the country of origin of the CV axle P art Number MFG#: TO-68398BA will be Thailand for marking purposes. The holding set forth above applies only to the specific factual situation and merchandise description as identified in the ruling request. This position is clearly set forth in Title 19, Code of Federal Regulations (CFR), Section 177.9(b)(1). This section states that a ruling letter is issued on the assumption that all of the information furnished in the ruling letter, whether directly, by reference, or by implication, is accurate and complete in every material respect. In the event that the facts are modified in any way, or if the goods do not conform to these facts at time of importation, you should bring this to the attention of U.S. Customs and Border Protection (CBP) and submit a request for a new ruling in accordance with 19 CFR 177.2. Additionally, we note that the material facts described in the foregoing ruling may be subject to periodic verification by CBP. This ruling is being issued under the provisions of Part 177 of the Customs and Border Protection Regulations (19 C.F.R. 177). A copy of the ruling or the control number indicated above should be provided with the entry documents filed at the time this merchandise is imported. If you have any questions regarding the ruling, please contact National Import Specialist Liana Alvarez at liana.alvarez@cbp.dhs.gov. Sincerely, (for) Evan Conceicao Designated Official Performing the Duties of the Division Director National Commodity Specialist Division